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KPMG article: Tariffs and advance pricing agreements (APAs)

Situations in which tariffs affect APAs, and potential resolutions

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NOVEMBER 21, 2025

The many tariff announcements and implementations by the Trump Administration in 2025 have far-reaching implications for transfer pricing. The significant uncertainty about the timing, country-by-country (CbC) application, and size of the tariffs magnifies the effect on transfer pricing because setting transfer pricing policies is both implicitly prospective and often closely intertwined with the global supply chain. This is especially true in the context of advance pricing agreements (APAs), which are intended to be prospective processes that address future periods.

Read a November 2025 article* prepared by KPMG LLP tax professionals that examines situations in which tariffs affect APAs, and potential resolutions based on how competent authorities historically have addressed similar issues.

*This article appears in Tax Notes Federal (November 10, 2025) and is provided with permission.

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